WAPFSA members Samantha Dewhirst and Stephen Munro from the Centre for Animal Rehabilitation and Education, C.A.R.E, invited the members of the Wildlife Wellbeing Forum to watch their presentation today. The objective of the presentation is to advise the Department of Forestry, Fisheries and the Environment and the Provincial Conservation Agencies, that there is a need to comply with the new provision of NEM:BA which now encompasses animal well-being. The presentation was also to encourage the increased protection of primates.

WAPFSA Members Agree and Request the Following from the Department of Forestry, Fisheries and the Environment:

  1. All indigenous primates must be added to the TOPS list
  2. Complex NDF’s are required for all indigenous primate species
  3. Norms and Standards for all indigenous primate species need to be developed
  4. A moratorium should be put in place until the NDF and N&S process, including transparent stakeholder consultation, is completed.


©WAPFSA 2024. All Rights Reserved.


The Members of the Wildlife Animal Protection Forum of South Africa addressed an urgent letter to the Chief Executive Officer of the Mpumalanga Tourism and Parks Agency with regard to their concerns about permits issued by the MTPA which would enable the cruel, indiscriminate and unscientific management of vervet monkeys in Mpumalanga.


The Wildlife Animal Protection Forum of South Africa (WAPFSA), a collective of thirty organisations, has a history of interest in the protection and conservation of wild animals in South Africa, sharing a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, climate, indigenous and public advocacy backgrounds.

Members of WAPFSA are also part of the Ministerial Wildlife Well-being Forum, instituted by the Department of Forestry, Fishery and the Environment (DFFE) in May 2023, by special request of Minister Barbara Creecy, in order to consult with organisations focused on best practices for the protection of wildlife.

The NEM:BA amendments came into effect on 30 June 2023. The Honourable Minister of Forestry, Fisheries and Environment, is currently in the process of implementing a legislative mandate to prohibit activities that may have a negative impact on the well-being of wild animals and to make regulations in relation to the well-being of wild animals, as per Section 2 of NEM:BA.

In the aforementioned section of NEM:BA, it is specified that all procedural activities that constitute biodiversity management, conservation and sustainable use of wild animals, including the issuing of permits, must consider the well-being of animals.

Section 9A of NEM:BA in particular, refers to any activity where there is reasonable evidence of a potential negative impact on animal well-being, using the wording “that may have a negative impact” which means that it is not required to have absolute proof of a negative impact to prohibit any activity. It implies that a precautionary approach, in line with the NEMA principles, must prevail.


WAPFSA members wrote a letter to the Minister of Forestry, Fisheries and the Environment on the 14th December 2023 requesting the inclusion six indigenous non-hum primate species in the South African Threatened or Protected Species Listing.

It is the Minister’s discretion to list species that fall into the criteria in Section 56 (1) (d): protected species. Such species do not necessarily have to be mentioned in other conservation lists such as the IUCN List or any other external lists. Provided that the proposed species fall into the description of those categories, they can be added to the TOPS list.

This followed the formal request from WAPFSA members on the 21st November 2023.

Image Credit: KVET Pringle Bay, South Africa

©WAPFSA 2023. All Rights Reserved.


Despite new provisions in NEM:BA and a new vision of “secured, restored, and rewilded natural landscapes with thriving populations of Elephant, Lion, Rhino, and Leopard, as indicators for a vibrant, responsible, inclusive, transformed, and sustainable wildlife sector” this version of the TOPS Regulations remains focussed on the monetization of wildlife, including the endorsement of the continuation of certain activities such as commercial exhibitions, travelling exhibition of TOPS species, which include zoos and circuses and the continuation of the breeding, trading and exporting of TOPS.

In a reply from Minister Barbara Creecy to a letter from WAPFSA members Ban Animal Trading/EMS Foundation:  “The legislative mandate to regulate the well-being of wild animals, which has been included in NEM:BA as an amendment through the National Environmental Management Laws Amendment Act, 2022 (Act No. 2 of 2022), came into force on 30 June 2023 when Proclamation Notice No. 125 was published in Government Gazette No. 48869. I now have the legislative mandate to prohibit activities that may have a negative impact on the well-being of wild animals, and to make regulations in relation to the well-being of wild animals. These legislative amendments will be initiated in due course.”

WAPFSA members have proposed the addition of non-human indigenous primates to the current TOPS list as protected species. 

South Africa is home to six indigenous non-human primate species: the Chacma baboon, Samango monkey, Vervet monkey, Thick-tailed Bushbaby, Southern lesser Bushbaby, and Mozambique dwarfed Bushbaby.

WAPFSA Members strongly support the fact that non-human primates have high conservation value and national importance which require regulation in order to ensure that these species are managed in an ecologically sustainable manner and are protected in compliance with Section 24 of the Constitution.

©WAPFSA 2023. All Rights Reserved.



The Wildlife Animal Protection Forum of South Africa WAPFSA is a collaborative network consisting of 30 (thirty) organisations representing the interests of wild animals and the natural environment as a vehicle with which to engage with the South African government on subject matter which includes, amongst other, wild animal protection, ethical and compassionate conservation, welfare, biodiversity loss and climate change.

South Africa is home to the world’s largest commercial lion farming industry. Lions are bred, often in appalling conditions, they are exploited for profit at every stage of their short lives.

At some facilities in South Africa cubs are removed from their mothers within a few days of their birth and are placed in the care of unsuspecting foreign and local volunteers who pay handsomely for the opportunity to look after “orphaned lions and other big cats”. Captive lions and other big cat cubs are also utilised in cub petting and various tourist interaction industries such as “walking with lions”.

When the cubs have reached the desired age and are no longer considered safe to be utilised in the tourist industry some of the lions are hunted for trophies either for the local hunting industry or for trophies that are exported to countries that condone canned lion hunting. Canned lion hunting reserves in South Africa typically have reinforced fences to prevent the lions from escaping during a hunt. Some of the lions are kept in small enclosures so that hunters with minimal skill, energy, patience or time can still successfully kill them.

The Members of WAPFSA are pleased that the Minister and the Department of Forestry, Fisheries and the Environment are finally initiating concrete steps against this distasteful industry. We encourage the South African government to do more to prevent the disturbing practices taking place at these breeding facilities.

WAPFSA members remain concerned about the trade, including live lions, the hunt and consumption of lions and all big cats and they stress the need for a just transition and re-establishment of harmonious coexistence with Nature and the protection of the web of life.

WAPFSA members support the acknowledgement of sentience in this Document and recommend that sentience is included and recognised in all DFFE policies and legislation in relation to wildlife. The inclusion of sentience is in line with the implementation of NEM:BA and the principles of wildlife well-being.

In the Draft prohibition, we noted the mention of the prohibition, of the introduction of live specimens of African lion; this therefore covers the prohibition of breeding and introducing new cubs. WAPFSA members are of the strong opinion that sentience should be referenced in this Prohibition and all the policies in relation to wildlife, underscoring the current efforts to implement principles of animal well-being as stated in NEM:BA and they stress that sentience should for no reason been removed in the finalised version of the document.

WAPFSA members would like the Draft Prohibition to properly address the issue of stockpiling, and implement the abolishment of all big cat bone stockpiles.

The prohibition to breed ALL big cats in South Africa is urgently required as currently there is a lack of effective monitoring and regulation at captive breeding facilities to monitor births, deaths transportation of live cats and the disposal of carcasses. This means that captive breeding facilities can act as a conduit for illegal and illicit trade. Similarly, prohibitions should be urgently promulgated to end the handling of, petting of and interactions with lions by humans for commercial purposes.

©WAPFSA 2023. All Rights Reserved.


WAPFSA members support many elements contained in this Draft Policy Position, which are also in line with the White paper, these include:

  1. “Thriving People and Nature”, which reconnects with Ubuntu, the Indigenous Knowledge and the principles of Harmonious Coexistence and is consistent with the United Nations Environment Program’s Living in Harmony with Nature by 2050;
  2. “South Africa’s priority is to secure the survival of species in the wild”;
  3. “Focus primarily on correcting unsustainable practices”;
  4. “The environment is protected” as a priority;
  5. “Duty of care” at the biodiversity, species and individual level
  6. The well-being of wildlife is recognised, including the “well-being of individual animals”
  7. “End the Captive keeping of Lion for commercial purposes” and
  8. “Potentially apply this to other species”;
  9. “Phasing out the domestication and intensification of management of Rhinoceros”.

WAPFSA members are, however, deeply concerned about the emphasis given to the set of human interactions that produce, trade, hunt and consume wildlife euphemistically known as the wildlife economy.

The White Paper on Conservation and Sustainable Use of South Africa`s Biodiversity (2022) although presenting the wildlife economy as an opportunity for growth, also indicates that the consumptive practices associated with it can have negative impacts if conducted too intensively, or inappropriately.

©WAPFSA 2023. All Rights Reserved.


The Wildlife Animal Protection Forum South Africa (WAPFSA), consists of a community of diverse South African-based organisations who share similar values, knowledge and objectives.  WAPFSA collectively offers a formidable body of expertise and advocacy drawn from different sectors, including but not limited to, scientific, environmental, legal, welfare, rights, social justice and indigenous knowledge. 

Member organisations of the Wildlife Animal Protection Forum of South Africa have written an open letter to Minister Barbara Creecy, amongst others, highlighting their concerns about an elephant hunt which took place in Balule Nature Reserve, in Limpopo Province of South Africa on the 3rd September 2023.

The Balule Nature Reserve forms part of the Associated Private Nature Reserves, (APNR), an association of privately owned nature reserves bordering the Kruger National Park (KNP). The fences were dropped in 1993 – before the end of apartheid – on the premise of creating ‘ecological unity’ between the APNR and the KNP itself. Commercial hunting, in the 1996 agreement, was not mentioned at all. Animals under public custodianship (KNP) now move freely between the APNR and the KNP. Far from creating ecological unity, however, they are treated as res nullius (nobody’s property) in the APNR and are hunted. South African National Parks (SANParks) has never addressed this problem.

The elephant bulls that are commercially trophy hunted in the Balule Nature Reserve form part of South Africa’s national heritage but they are being killed for the benefit of a small number of wealthy white landowners as the amount of money actually accruing to local communities remains unknown. 

On Sunday the 3rd of September 2023, a bull elephant was shot and wounded by a trophy hunter in the Maseke area of the Balule Nature Reserve. Obviously, the traumatised and injured elephant attempted to get away. He left the Maseke area and went into the neighbouring Grietjie Private Nature Reserve. The deputy head warden of Maseke initiated a search for the elephant with a helicopter.  The elephant was located and driven back to Maseke using the helicopter where he was killed. 

According to Mr Ian Novak the General Manager of Balule Nature Reserve, the elephant hunt was legal and no Greater Limpopo Transfrontier Conservation Area Reserve Protocol violations were committed.

Maseke is a region located within the Balule Nature Reserve.  Maseke Game Reserve, Balule Nature Reserve and Grietjie Nature Reserve all form part of the Greater Limpopo Transfrontier Conservation Area Reserve. 

The Greater Kruger Hunting Protocol was developed and endorsed by signatories which included representatives from South African National Parks, Limpopo Economic Development, Environment and Tourism and Mpumalanga Tourism and Parks Agencies.   The number of elephants that are allowed to be hunted annually is determined by the Associated Private Nature Reserves ecological panel and reviewed and then endorsed by SANParks and the Limpopo Economic Development, Environment and Tourism Biodiversity. 

Many international visitors to South Africa, and to the Kruger National Park, are unaware that the hunting of elephants is permissible.  The Kruger National Park was named as one of the World Wonders on the new list which was published on the 14th of September 2023.  “A listing that reveals global landmarks and natural marvels that the world is most curious about.”  The Kruger National Park forms part of the UNESCO Kruger to Canyon Biosphere Reserve. 

The fences separating all the Associated Private Nature Reserves and the Kruger National Park were dropped to reduce fragmentation, facilitate migration and increase space for wildlife and access to resources, in other words, to increase the well-being of animals. The perennial Olifants River flows for approximately 20 km through the centre of the Balule reserve and, for example, elephants cross Maseke into Grietjie to access the river. 

The killing of this particular elephant was described as being upsetting to some and not an ideal situation. Of major concern is that this is not the first time that there has been a controversial elephant hunt on Maseke.  On the 23rd November 2018, Sharon Haussmann, the then chairperson of Balule, initiated a full investigation after an elephant was shot thirteen times in front of guests. Sharon Haussman described that incident as completely unethical, inconsiderate and a huge embarrassment for Balule.   

In the APNR, current and historical mismanagement, breaches of the Greater Kruger Hunting Protocols, and sometimes even negligence during trophy hunts, reflect not only badly on the hunting fraternity, but also on the photographic safari or eco-tourism sector in the Greater Kruger National Park and South Africa as a whole. Some examples include:

  1. Early 2005, an elephant hunted in the Klaserie was shot 21 times before it succumbed.
  2. In June 2005, an American hunter wounded an elephant in Balule, but only killed it 24 hours later.
  3. In March 2006, a lion, one of a well-known pair known as the “Sohebele brothers” was shot and wounded in the Umbabat, but the hunter was unable to kill the animal, as its brother refused to leave the scene. The hunter later repeatedly drove a tractor at the lions in an attempt to separate them but failed. The lion was killed by rangers only the following morning.
  4. Later that month, a large, one-tusked male elephant was shot and wounded by a Spanish hunter in the Umbabat, believed to have fled into the KNP and was not found since.
  5. March 2013, an elephant was shot in the very close proximity to Ingwelala’s eastern boundary. The wounded elephantl ran directly south towards Motswari Lodge and was followed by the hunting party, who continued to fire 20+ shots before it was finally killed in the close proximity to the lodge with many guests. Motswari Lodge was never informed that this hunt was to take place and was caught completely off-guard. The effect on their guests and staff was devastating.
  6. In August 2018, a scheduled elephant hunt conducted in Balule led to the illegal killing of a collared male elephant. Mpumalanga Tourism and Parks Authority (MTPA) laid criminal charges and the warden was subsequently convicted.
  7. In December 2018, a young elephant was shot multiple times in Balule in front of photographic safari tourists staying at a neighbouring property.

After the latest unfortunate hunting incident, the General Manager of Balule stated that : “Hunting is never an exact science and no matter how many targets a client shoots at before the hunt, there is never any guarantee that he will make the perfect shot when faced with the real thing. The nature of a hunt is unpredictable and this is not a reflection on the capabilities of the Maseke Reserve Representative.

WAPFSA is ethically opposed to the hunting and killing of any animal for sport or pleasure.  WAPFSA has openly challenged claims made by proponents of trophy hunting that it delivers significant conservation and community benefits or that it positively contributes to the sustainable use of wildlife in South Africa.

WAPFSA has previously highlighted how trophy hunting is rooted in colonial modes of extraction which continues to perpetuate notions of abuse, subjugation, control and inequality. Dr Muchazondida Mkono’s research[1] has found that trophy hunting is an objectionable consequence of a complex historical and postcolonial association.  Africans have a deep resentment towards what is viewed as the neo-colonial character of trophy hunting, in the way it privileges Western elites in accessing Africa’s wildlife. 

WAPFSA also opposes trophy hunting based on scientific evidence. In relation to elephants, research challenges the assumptions by trophy hunters that selectively killing older male elephants has no negative consequences because they are “redundant” in the population. Elephants are sentient beings who live socially complex lives through relationships which radiate out from a mother-offspring bond through families, clans, and sub populations. Independent males form long-term friendships. Elephants communicate through more than 300 gestures, complex speech and glandular secretions. They contemplate, negotiate, collaborate, plan and are aware of death. They care about their lives. The  killing of older males has a detrimental effect on the wider elephant society through loss of leaders crucial to younger male navigation. In addition, when trophy hunters eliminate these older bulls, they destroy elephant family integrity (through trauma and removal of the discipline and knowledge transfer functions executed by patriarchs) and force matriarchs to mate with younger bulls they would otherwise not have selected, thereby skewing reproduction patterns. 

According to the General Manager of the Balule Nature Reserve, Maseke is permitted to kill twelve elephants per year, a practise which he states will continue, and one which is, in their opinion, in line with the constitution of South Africa. 

However, in terms of NEM:BA, the South African government is entitled to make policy decisions in relation to contentious and damaging practices, decisions that are in the public interest, prioritising public opinion and the economic benefits of the public.  

NEM:BA includes the notion of “well-being”, which is defined as the “holistic circumstances and conditions of an animal, which are conducive to its physical, physiological and mental health and quality of life, including the ability to cope with its environment.” The consideration of the well-being of animals must be included in the management, conservation and sustainable use thereof”. 

The entirely new section, 9A in NEM:BA, empowers the DFFE Minister to prohibit certain activities “that may negatively impact on the well-being of an animal […]” and create new offences “relating to non-compliance with s9A”; S101, then, refers to accountability of “person who contravenes or fails to comply […]” 

It is our considered view that well-being falls within DFFE and the Minister’s legal mandate. The amendment to section 2 makes it necessary for well-being to be specifically considered, including when permits are granted, including those for hunting and all decisions that constitute “management, conservation and sustainable use” of animals.

S9A is widely drafted and applies to any activity, including hunting, as well as any other activities not so defined, provided there was reasonable evidence of a potential negative impact on wellbeing. S9A also uses the wording “that may have a negative impact” which means that the Minister is not required to provide absolute proof of a negative impact before making a prohibition. 

Given the above amendments to NEM:BA, it is competent for the Honourable Minister to: 

  1. Prohibit specific activities involving animals under s9A on the basis that there is already evidence that the activities impact negatively on wellbeing; and/or 
  2. Publish a notice under section 9A prohibiting specific activities if there is reasonable evidence to support the view that this may have a negative effect on well-being;
  3. Make regulations relating to the well-being of animals under s97; and/or
  4. Challenge decisions of conservation officials which constitute administrative action (such as permitting decisions or the setting of quotas) on the basis that well-being is a relevant factor and has not been considered or on the basis that the decision would have a negative impact on the well-being of an animal or animals.

The aforementioned letter from the General Manager of Balule concluded that the hunt was conducted in accordance with the requirements and approved protocols. Have the representatives from South African National Parks, Limpopo Economic Development, Environment and Tourism and Mpumalanga Tourism and Parks Agencies taken the amendments to NEM:BA into consideration, are their approved protocols compliant with the national legislation and particularly with the duty of taking into account the well-being of animals in any hunt?

WAPFSA is aware that there is an ongoing court case, which seeks to challenge hunting and export quotas permitted by the government, in the Western Cape High Court. In light of this legal challenge, the undesigning members of WAPFSA are requesting Minister Creecy to: 

  1. Investigate if permits to hunt twelve elephants were issued, as specified in the letter from the Balule administration, despite the interim interdict. 
  2. Revoke permits and halt any further hunt of elephants as well as rhinos, leopards and lions as per interdict, 
  3. AS this is not the first incident, withhold hunting permits to the Maseke-based hunting entity involved; and 
  4. Finally address the complex issue of trophy hunting as it is allowed in certain unfenced reserves of the APNR and elsewhere, and is incompatible with individual animal and species’ well-being considerations. 

[1] Mucha Mkono (2019) Neo-colonialism and greed: Africans’ views on trophy hunting in social media, Journal of Sustainable Tourism, 27:5, 689-704, DOI: 10.1080/09669582.2019.1604719

Image Credit: EMS Foundation, an elephant in the Kruger National Park February 2023

©WAPFSA 2023. All Rights Reserved.


“It has come to the attention of WAPFSA that Wildlife Ranching South Africa (WRSA) has included WAPFSA on the Forum and Membership menu of their website, and in addition, mistakenly used the South African Department of Forestry, Fisheries and Environment logo.

WAPFSA has requested that WRSA urgently removes WAPFSA from the WRSA website.”

©WAPFSA 2023. All Rights Reserved.


On the 3rd September 2023 WAPFSA formally objected to the construction of a Eskom Foskor-Merensky 400kV power line and the associated sustain works in the Mopane and Sekhukhune district municipalities on the grounds that this project will have disastrous negative consequences for wildlife conservation in an important wildlife corridor and sensitive biodiversity area.

The proposed power line project stands in stark contrast to the principles and goals enshrined in the recently approved White Paper on Conservation and Sustainable Use of South Africa’s Biodiversity (the ‘White Paper’).

In light of the objections listed WAPFSA is of the view that the DSR requires significant revision, including consultation with environmental experts before the process can be allowed to continue.

Image Credit: Gurcharan Roopra

©WAPFSA 2023. All Rights Reserved.


The Wildlife Animal Protection Forum of South Africa (WAPFSA) wishes to express our deep concern that time is running out for the Hunting Trophies (Import Prohibition) Bill, which carries overwhelming public support and would fulfil a government manifesto commitment, to become law. 

The Bill’s Committee Stage in the House of Lords has yet to be scheduled, and with the current parliamentary session due to end in November, there is a real danger that the Bill will run out of time. Lords Hamilton and Mancroft have also tabled amendments which would fatally weaken the Bill. 

WAPFSA is a community of diverse South African-based organisations that share certain values, knowledge and objectives and that collectively comprise a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, indigenous and public advocacy backgrounds.

The undersigned organisations and community representatives are widely supported by wildlife conservationists across the African continent and beyond and would like to take this opportunity to share our African perspective on the negative impacts of the commercialisation, advertisement and sale of trophy hunts of African endangered and protected species with you. 

Countries across Europe have acknowledged the fact that trophy hunting has little connection with conservation, on the 13th of December 2022 the Finnish Parliament approved a new nature conservation law that includes the banning of imports of hunting trophies from endangered species. 

The Finnish Nature Conservation Act will enter into force on the 1st of June 2023. In 2015 France specifically banned the import of lion trophies. In 2016 the Netherlands banned the import of hunting trophies of over 200 hundred species. In March 2022 the Belgium Parliament adopted a resolution urging the government to immediately end the authorisation of trophy import permits for certain threatened and endangered species. 

Scientists tell us that removing male mammals from their populations can increase the risks of species extinction. By selecting the most impressive, largest, most rare, usually male, that is usually the strongest and fittest in order to become the best trophy (largest tusks and thickest manes), trophy hunters affect reproductivity thereby weakening populations’ genetic health and variation, dislocating the surviving members of the group’s social structure, disrupting bonds and behaviours.  

“Hunting Africa, Trophy Hunting, Neo-colonialism and Land” is an investigative report written by Professor Sian Sullivan, in which she confirms Safari Club International World Hunting Award Field Journal dedicates more pages to Africa than any other continent.  “These figures clearly show the dependence of the trophy hunting industry on securing access to Africa’s hunting grounds. Given that the hunting industry claims to African lands requires removal of African peoples and constraints on local production practices, it arguably promotes and extends colonial patterns of enclosure.

Trophy hunting is rooted in colonial modes of extraction that perpetuate notions of abuse, subjugation, control and inequality, including gender inequality Dr Muchazondida Mkono’s research[1] has found that trophy hunting is an objectionable consequence of a complex historical and postcolonial association.  Africans have a deep resentment towards what is viewed as the neo-colonial character of trophy hunting, in the way it privileges Western elites in accessing Africa’s wildlife. 

Proponents of trophy hunting argue that trophy hunting provides vast economic opportunities for local communities whereas, in truth, the economic benefits of big game hunting are wildly exaggerated and pale in comparison to the economic possibilities of eco-tourism. Yet, according to a 2013 study by Economists at Large, only 3% of the revenue generated by trophy hunting remains with local communities in Africa. In addition, hunting quotas are often set according to economic interests and market demand rather than population abundance and are not based on scientific data or standards. 

In reality, trophy hunting is an elitist hobby for millionaires and billionaires who pay huge fees to kill large exotic and rare animals. Cash-strapped and corrupt governments in developing countries allow the colonialist sport to continue. According to a Report by Good Governance Africa, compared with tourism, trophy hunting provides very little benefit.  The Report also questions whether the legally sanctioned killing of wild animals can be reasonably tolerated. 

When there is a conflict between humans and large wildlife in Africa, this conflict is managed in fruitless ways that only have the purpose to generate revenue within the strict elite circle of the trophy hunting industry, without solving the conflict issue. Alternative, science-based, non-invasive, cost-effective methods are scraped out because of the constructed idea that trophy hunting has to be part of any conservation protocol. 

Projects that offer optimal alternatives to trophy hunting, in terms of improving the livelihoods of local communities, based on regenerative, climate-resilient practices and alternative conservation activities that reject and avoid violence, subjugation and extraction in favour of more ecologically sustainable and dignifying activities exist in countries in Africa, including Tanzania, South Africa, Namibia, MalawiZimbabweZambia, Kenya, Uganda, Rwanda, Lesotho, Angola, Botswana, Eswatini, and Madagascar. 

These practices promote fair share and equity, women and youth empowerment and self-sufficiency. These projects focus on improving farming productivity and food security via climate-smart agricultural practices they encourage economic development and wildlife coexistence and resilience. We are aware that these often activities struggle to flourish because of the competition with extractive, immediate-reward models and sectors which are plagued with corruption and nepotism as the hunting sector. 

In Namibia, for example, more than 95% of trophy hunts are conducted on private land and only about 2 per cent in communal conservancies.[1] Hardly any financial revenue is derived from trophy hunting in these communities. Governments are not interested 

In monitoring if revenues are allocated fairly. Furthermore, many locals feel excluded from the benefits their wildlife offers, since trophy hunting is a privilege of wealthy foreign tourists, while they themselves are mostly prohibited to hunt for subsidence. So instead of promoting economic independency and ensuring the livelihoods of local communities, trophy hunting deepens inequality and consolidates social injustice. 

In July 2022, in a joint position statement on Trophy Hunting, 171 animal protection organisations, including 51 NGOs from Africa, asked for trophy hunting to be banned. 

A recently published survey indicated that in South Africa the opposition to trophy hunting has increased from 64% in 2020 to 68% in 2022.  The survey included data sourced from a diverse South African demographic across all provinces. The key findings from the IPSOS survey include:

  • 68% of South Africans fully oppose or oppose to some extent the practice of trophy hunting – an increase from 56% in a similar 2018 survey.
  • 65% of South Africans fully oppose or oppose to some extent the practice of canned lion hunting – an increase from 60% in a similar 2018 survey. 
  • 64% of South Africans disagree with the trophy hunting of elephants, rhinos, and leopards.
  • 63% of South Africans disagree with the trophy hunting of lions.
  • 66% of South Africans disagree with the trophy hunting of hippos.
  • 60% of South Africans disagree with the trophy hunting of giraffes.
  • Regarding the 2022 hunting and export quotas announced by the Department of Forestry, Fisheries and the Environment (DFFE) in February 2022, 63% oppose the quota for 150 elephants, 62% oppose the quota for 10 black rhinos, and 61% oppose the quota for 10 leopards.

World Animal Protection recently commissioned research into public attitudes towards trophy hunting, surveying 10,900 people from around the world, including international tourists from countries who most frequently visit  Africa. The research confirmed that international tourists want to see wildlife-friendly experiences and an end to trophy hunting. Tourists want to see wildlife alive and thriving and protected in a humane and ethical manner.  

study by the World Travel & Tourism Council confirmed that wildlife is worth more alive than deadAnother study of eight African countries by economists concluded that overall, tourism which relies heavily on wildlife contributed between 2.8% and 5.1% of GDP, and foreign trophy hunters made up less than 0.03% of the same GDP on average. Similarly, photo safaris, in comparison, allowed for sustainable, lucrative tourism activities without killing wildlife.The International Union for the Conservation of Nature Ethics Specialist Group wrote to the German government to ask for an end to the practice of trophy hunting imports for ethical, ecological and legal reasons. Professor Klaus Bosselmann, chair of the aforementioned group, said: “Trophy hunting unnecessarily threatens the survival and genetic integrity of protected species in the midst of the current crisis of the sixth mass species extinction. It is overdue that Germany, as the largest importer of hunting trophies in the EU, takes action.” Members of WAPFSA congratulate the German Ministry of the Environment, Steffi Lemke’s, announcement of their intention to restrict the import of hunting trophies from protected species in Germany.

WAPFSA also welcomed the announcement by IEG Italian Exhibition Group SpA in 2022 to discontinue Italy’s largest hunting fair in Vincenza in light of the fact that the event was incompatible with environmental values.  

As one of the countries directly associated with the outdated colonial practice of trophy hunting, the United Kingdom has an obligation as well as an opportunity to take leadership position on this matter.

While some members of the scientific fraternity do support the old-styled trophy hunting model, it is true that this scientific fraternity is largely funded by trophy hunting outfitters, including Safari Club International. While we understand the arguments based on commercial justification for prolonging these colonialist practices, WAPFSA recognises that these arguments do not represent Nature’s best interests, which are calling for more respectful alternatives in support of responsible biodiversity management. These models do already exist, some of which are detailed in this submission.

The United Kingdom has a real opportunity to take a firm stand against the trophy hunting industry. WAPFSA, therefore, urges you to fulfil your government’s commitment by ensuring that the Bill is given sufficient parliamentary time to pass into law during the current parliamentary session and that any amendments aimed at weakening the Bill are robustly opposed. 

1 Mucha Mkono (2019) Neo-colonialism and greed: Africans’ views on trophy hunting in social media, Journal of Sustainable Tourism, 27:5, 689-704, DOI: 10.1080/09669582.2019.1604719

2 C. MacLaren, J. Perche & A. Middleto, The value of hunting for conservation in the context of the biodiversity economy. REPORT – available at the link 2019-06-Hunting_report.pdf (

©WAPFSA 2023. All Rights Reserved.


WAPFSA wrote a letter to the Minister of Forestry, Fisheries and the Environment with regard to Namibia’s decision to kill 86000 Cape Fur Seals for commercial purposes.

The decision has been taken by the Namibian government to slaughter 86000 Cape fur seals despite a decrease in demand for seal pups and the mounting opposition from conservationists.  The brutal financially motivated killing of Cape fur seals in Namibia should be of concern to us all, because of the potential negative cascading effects on South African marine ecosystems.   

One such negative effect relates to sharks. The International Union for Conservation of Nature (IUCN) has warned that 37.5% of the 1 200 known species of sharks are threatened with extinction. South Africa is a Party to the Convention on the Conservation of Migratory Species of Wild Animals, also known as the Convention on Migratory Species (CMS) with the objective to conserve migratory species throughout their ranges, including sharks that are listed in CMS Appendix I and II; according to CMS’s Article 2 and 2(2) and 2(3), (Parties) must take action, 

whenever possible and appropriate […] paying special attention to migratory species the conservation status of which is unfavourable and taking individually or in cooperation appropriate and necessary steps to conserve such species and their habitat [..] to avoid any migratory species becoming endangered;  […] shall endeavour to provide immediate protection for migratory species included in Appendix I and […] shall endeavour to conclude agreements covering the conservation and management of migratory species included in Appendix II.

Namibia is one of a few countries that are “participating non-parties” to the CMS which implies that they are party to one or more of the agreements, and/or have signed one or more of the MOUs, for example, they have signed an MOU for the protection of the Atlantic Turtle. 

The members of the Wildlife Animal Protection Forum South Africa (WAPFSA) recently prepared comments which were delivered to the South African Department of Forestry, Fisheries and the Environment (DFFE) on the Shark Biodiversity Management Plan, drafted in order to protect sharks. In direct contrast, Namibia’s Ministry of Fisheries approved a quota for the harvesting or culling of 80 000 seal pups and 6000 seal bulls to commence from the 1st of July 2023 and to continue till November. The Cape fur seal is one of the primary sources of food for many large sharks including the great white shark. 

On the 11th of July 2023, WAPFSA issued a public statement on the planned killing of seals in Namibia (see also Annexure I). The statement questioned the non-transparent and unscientific decision-making process with regard to this cruel and unacceptable slaughter. 

Two colonies of seals will be targeted during the planned slaughter period, the Cape Cross colony and the Walvis Bay colony, both near Swakopmund.  Of further concern is that both of these areas have a history of Cape fur seal mass mortality.  In   2020 and 2022, the phenomena of die-offs of the most common apex predator concerned local and international experts.  


According to scientific articles, the exploitation of seal body parts for trade in Southern Africa is a colonial relic dating back to the 17th century.  Seals were slaughtered indiscriminately by sailors, for skins, meat and oil and for three centuries until 1899.

The slaughter in the modern day continues even though it is socially unacceptable and highly contested.  The actual slaughter, paradoxically, takes place inside nature reserves; before sunrise, away from eyewitnesses, while the beaches are closed.  

The Cape fur seals, who are not nocturnal mammals, are surprised in the dark or predawn. Terrified pups are rounded up, forcibly separated from their mothers, and violently beaten to death while the mothers watch from a short distance, and helplessly exchange mother–pup vocal highly distressed calls. 

Scientific research has indicated that these marine mammals are sentient, alert and able to discriminate calls with high acoustic similarity and identify their offspring even in extremely large and numerous colonies. The call is the primary identification signal between mother and pup.  Labourers are employed to club the pup to death or kill them with pick handles or shoot them. Pups get so terrified that they vomit their mothers’ milk in fear. Once the slaughter for the day is completed, the seal carcasses are piled up, taken away from the area by trucks and the blood is cleaned and removed before the oblivious tourists arrive.


The Cape Fur Seal, and associated predators, range across the oceans of Southern Africa.   The Cape fur seal massacre in Namibia is promoted by short-sighted economic agendas, and it represents a threat to fragile local and extended ecosystems as well as to endangered species which are endemic to South Africa. 

The unjustified massacre of the Cape fur seal raises huge ethical, animal and human welfare, well-being and environmental concerns. 

The undersigning members of WAPFSA urge the DFFE Ministry to examine its objectives in terms of NEM:BA, to call for the protection of the Cape fur seal and to take all possible actions to halt stop this barbaric, unscientific and irresponsible massacre now, and to encourage long-term agreements to prevent this from happening in the future. 

©WAPFSA 2023. All Rights Reserved.


The Members of the Wildlife Animal Protection Forum of South Africa have expressed their concern in a letter regarding the Department of Forestry, Fisheries and the Environment’s capacity to host the monthly meetings of the Wildlife Well-Being Forum as recommended by Minister Barbara Creecy.

Read the full letter:

The Honourable Minister launched the WWBF on a live-streamed meeting on the 5th of May 2023, with the promise that there would be meaningful, ongoing consultation between the members of the Wildlife Well-Being Forum and the Department with the recommendation of organised monthly meetings.

A draft work plan was shared within the WWBF for comments in mid-May and a preliminary meeting was held on the 30th of May 2023. The agenda included the election of a Chair and the planning of monthly meetings to be discussed and diarised.

At the time, the DFFE expressed concerns about not having the capacity to fulfil this role, especially on a monthly basis. Some attendees took the view that DFFE should chair WWBF meetings while others suggested various solutions such as electing an alternative Chair. In closing, the Department made a commitment to organise and chair all future engagements stating that the next meeting would take place at the end of June 2023.

Despite this commitment by DFFE, no meetings were scheduled in June, July or August. Representatives of the various organisations have now been informed, after several follow-ups by some WAPFSA members, that the next WWBF engagement will only be scheduled for the 5th of September 2023.

Members of WAPFSA find this unacceptable, particularly given the pressing issues that need to be discussed.

The undersigning members of WAPFSA are concerned that the Department may not have the capacity for important engagement and consultation with our sector, which was a recommendation of the High-Level Panel in 2021 fully supported by the Minister.

If the Department does not have the capacity to chair these meetings with the frequency that is required, and as recommended by the Minister, the Department should allow alternative Chairs.

The Wildlife Animal Forum of South Africa was constituted with the objective of engaging with the Government on specific issues relevant to wildlife protection and well-being. WAPFSA is able to nominate a Chair from within its member ranks, who will have the necessary capacity to fulfil this role.

In addition, and related to the above, on the 19th May 2023, The Wildlife Animal Protection Forum South Africa (WAPFSA) sent the Honourable Minister a letter regarding the consultation processes. An urgent response to this letter is requested.

Image Credit: Rhinos in Africa

©WAPFSA 2023. All Rights Reserved.



The Wildlife Animal Protection Forum South Africa is a community consisting of twenty-five South African wildlife and environmental conservation organisations that share common values, knowledge and objectives and who collectively comprise of a body of expertise from different sectors including but not limited to scientific, legal, welfare, rights, social justice, indigenous and public advocacy backgrounds.

Namibia’s Ministry of Fisheries has issued a quota for the harvesting or culling of 80 000 seal pups and 6000 seal bulls. Mr Romeo Muyunda, spokesperson for the Namibian Environment Ministry said“If you let the seal population grow, they will consume the commercial amounts of fish.”   

The Namibian Ministry has said that the harvesting of seals contributes to state revenue for national development programs. “Namibia’s seal population has increased to the point where they exceeded by far the carrying capacity of the environment therefore it is humane to curb the unrestricted seal population to a level where they can be sustained by the environment,” the government said in a statement.    


The Cape Fur Seal is the most common seal species to be found in southern African waters. They occur from the Namibian west coast to East London on the east coast of South Africa. Their food consists mainly of shoaling pelagic fish such as pilchard, hake, Cape mackerel and snoek.  They also eat squid and crustaceans.  Cape Fur Seals are generalist feeders catching a wide variety of prey and are expected to feed on locally abundant prey species.  Cape fur seals forage within 220km of their colony. 

The uncontrolled exploitation of the Cape Fur Seal has previously led to a serious reduction in population numbers.  In 1983 they were protected in South Africa by an Act of the Cape Parliament and harvesting was controlled until 1990 when it was finally prohibited.  The protection of the seals and the halt to all sealing activities resulted in the recovery of the populations.  Sealing continues in Namibia where it is still permitted.  The effect of declining pelagic fish stocks on seal populations is a concern and the subject of several current research projects.            

Every year quotas are set for the commercial “harvesting” or culling of the Cape Fur Seal in Namibia.  Namibia is the only country in the Cape Fur Seal’s range in which commercial hunting is permitted.  Sealing occurs on two mainland colonies, Cape Cross and Wolf/Atlas Bay.  


Seals are killed for their fur which was traded globally however there is a marked reduction in demand due to the European market ban on seal imports.  

The Namibian harvesting season officially opened this year on the 1st of July 2023. Namibian seal products are now mainly exported to Asian markets, after twenty-seven countries, including the European Union, the United States of America, Mexico, and South Africa have banned the import of all seal products.  

Of the Asian countries, the main market for Namibia’s seal cull has shifted to China.  Seal penis is a delicacy enjoyed in China and seal fat is used in beauty products.  According to a 2014 published report titled Grey Seal Management: Commercial use Opportunities and Challenges, Asian consumers, particularly athletes, consume a beverage called Dalishen Oral Liquid that is made from seal penis and testicles which they believe to be energizing and performance enhancing.  The report also suggests that seal meat could be processed as meatballs, sausages, pate and an infinite range of entrees targeting gourmet food and wine clubs. 

According to an article published in National Geographic in 2016, the oil derived from the blubber of the Cape Fur Seal advertised online as rich in Omega-3 fatty acids and allegedly is more readily absorbed by the human body given its mammalian source than fish oil.  Since 2005, Namibia exported 33 000 gallons of seal oil, a third of which was exported to China. 

Hatem Yavuz, the Namibian Honorary Consul to Turkey in 2012, was the main fur trader and buyer of seal skins from Namibia. According to an article published in 2014 he controlled 82 percent of the world’s seal fur trade. 

The Hatem Yavuz Group is based in Turkey and Australia, it represented, according to an article published in 2016, the largest trade of any mammal out of Africa.  An estimated 400 000 seal pelts from 2005 to 2015. According to Seven Network in Australia, the Yavuz Group controls 60 percent of the global market in seal products. 

In 2020 and 2021 the brutal slaughter of the Cape Fur Seal was put on hold because of the global COVID-19 pandemic. 


In 2022 it was reported that hundreds of dead Cape Fur Seals had washed up on a stretch of Namibian coastline.  Hundreds upon hundreds of dead seals littered the beaches at Pelican Point, a 5km colony situated in Walvis Bay. Scientists from Stellenbosch University and Sea Search believed the cause of the death of these seals was linked to biotoxins namely domoic acid, produced by certain types of algae. The seals did not die of malnutrition, pollution, or exposure to noise according to the Namibian Dolphin Project

In 2020 thousands of Cape Fur Seals died in what was termed an abortion storm. An unusual mortality event among one of the world’s largest seal colonies caused great concern among scientists.  More than 5000 aborted Cape Fur Seal fetuses washed up on Central Namibia’s Pelican Point shore over a period of a few months.  

The spike in deaths was far higher than normally witnessed a phenomenon that worried local and international experts.  “If you are seeing die-offs of the most common apex predator in that ecosystem, we should not just be concerned about the seals, we should be concerned about the ecosystem and this event should be flashing big warning lights”.

Ecocide was defined as “Unlawful or wanton acts committed with knowledge that there is a substantial likelihood of severe and widespread or long-term damage to the environment being caused by those acts”.

Naude Dreyer, co-founder of Ocean Conservation Namibia Environmental Trust has expressed dismay over the lack of scientific research and decision-making based on demand.  He has emphasized the potential disruption to the ecosystem caused by the removal of seal bulls.  

Seals of Nam, a Namibian non-profit founded in 2010 with the goal of ending the country’s sealing industry is still hopeful that the ever-shrinking markets for seal products because of the global outcry against the mass killing of seals will eventually kill the industry. 

Seal Protection Namibia a non-governmental organization is still seeking a ban on seal hunting on the grounds it is illegal and immoral. 

Footage of the seals being clubbed to death has enraged animal rights campaigners for years. Terrified pups are rounded up, separated from their mothers, and violently beaten to death.  The clubbing begins every morning at 6h00 am; then, at 9h00 am, the beaches have already been cleaned before the tourists arrive.

In 2012 Captain Pete Bethune founder of Earthrace Conservation witnessed the cull, and said“It remains the most harrowing thing I have ever witnessed.” 2015 The Seals of Nam partnered with social media experts from the Seal Army in a global outcry against the annual Namibian seal hunt.  

United Kingdom animal rights activist Ricky Gervais has joined other celebrities including George Lopez, Brigitte Bardot, Paul McCartney, Sara McLachlan, and Pamela Anderson who have condemned seal hunts in both Namibia and Canada.  People for the Ethical Treatment of Animals has stated that the argument used by the Namibian government, protecting the fisheries because there is an issue of seal overpopulation, is invalid: “Studies have shown that overfishing is to blame”, with overfishing being the practice of fishing beyond what is allowed by permits, either at a rate that does not allow repopulation of species or by fishing untargeted species(bycatch) that are protected or threatened with extinction.

Studies indicate that overfishing is the primary cause of marine defaunation, while Illegal, Unreported, Unregulated fishing (IUU) is widely indicated by scientists as the cause of biodiversity loss, fish depletion and increased risks of shark and other endangered species extinction.   

The Director of the conservation organization called, International Fund for Animal Welfare in South Africa, Jason Bell,  commented on the proposed 2023 Namibian seal hunt “There is no justification for the killing, this is a purely political and economic issue, with very little concern for animal welfare.”

Seal Alert SA has expressed concerns about nursing seal pups being killed illegally.  Namibia is the only country in the world that allows the killing of nursing seal pups.  Seal Alert SA launched a bid in 2022 to interdict the seal cull.  The Ombudsman’s office said that Seal Alert SA did not have a mandate to make recommendations to the Namibian government.   


Despite a decline in demand for seal pups and the mounting opposition from conservationists, the Namibian government has decided to continue with the annual cull. 

WAPFSA Members hereby lend their unwavering support to all the organizations and individuals who have and continue to tirelessly defend the right to survival and the end to the abhorrent mass killing of the Cape Fur Seals in Namibia. 

WAPFSA was initiated in 2017 as a collaborative network representing the interests of wild animals as a vehicle with which to engage governments on animal protection, ethical and compassionate conservation, welfare, and biodiversity loss issues amongst others.

The Cape Fur Seal, as well as its direct predators’ ranges, include the oceans of South Africa.  We, therefore, agree that the protection of this mammal is of great importance to the continuance of a healthy aquatic ecosystem. We stand together on the shoulders of those before us, against the barbaric, unscientific and irresponsible, money-driven massacre of these mammals. 

Image Credit: Jean Tresfon



The Members of WAPFSA, who signed the aforementioned submission to the Deputy Director -General Ms Zintle Langa of the Department of Forestry, Fisheries and the Environment , belong to a community of diverse South African based organisations who share certain values, knowledge and objectives. WAPFSA members comprise of a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, indigenous and public advocacy backgrounds.

We are hopeful that the Department of Forestry, Fisheries and the Environment find this submission helpful because according the the International Union for Conservation of Nature (IUCN) 37.5 % of the 1200 species of sharks are currently threatened with extinction.

We are concerned that the Draft Shark Biodiversity Management Plan does not sufficiently and effectively address the reduction or the phasing out of the activities identified as major threats to the survival of shark species.

Image Credit: Jean Tresfon

©WAPFSA 2023. All Rights Reserved.


The Wildlife Animal Protection Forum South Africa (WAPFSA) is a network of diverse South African-based organisations that share certain values, knowledge and objectives and are comprised of expertise from different sectors including, but not limited to scientific, environmental, legal, animal welfare, animal rights, social justice, indigenous knowledge and public advocacy backgrounds.

On Friday 19th of May 2023 Members of WAPFSA wrote a letter to Minister Barbara Creecy. This is an excerpt from this communication:

WAPFSA thanks the Honourable Minister for establishing the Wildlife Well-being Forum.

In 2005, the Minister of Environment, Marthinus van Schalkwyk, established a consultative Wildlife Forum to engage quarterly with private entities about wildlife policy with the main objective being sustainable use. The Terms of Reference of this Forum were deliberately exclusive, discriminatory and exclusionary, thereby deliberately denying membership to other wildlife stakeholders including those working to protect and ethically conserve wild species within a one-health and welfare framework and striving to monitor and engage with all the issues discussed in the Wildlife Forum.

In February 2018 representatives of twenty-three wildlife and environmental protection organisations founded the Wildlife Animal Protection Forum South Africa (WAPFSA) and officially requested official acknowledgement from Minister for the Environment, Edna Molewa to engage with our sector.

However, not only were other stakeholders denied admission to this Forum, but no other parallel fora were established by the Government to evenly consult with other key interested and affected parties and stakeholders in the wildlife and biodiversity conservation and protection sector, despite continuous requests from the wildlife protection sector to be included.

The Wildlife Forum remains a limited and partial platform for stakeholder engagement which meets with government representatives behind closed doors to shape wildlife policy in South Africa. This has created a dysfunctional, inequitable and dualistic situation in relation to wildlife stakeholder engagement.

Following the recommendations of the High-Level Panel, in 2021, the process to establish a parallel forum, the Wildlife Well-being Forum, was initiated. We are pleased that this collaborative forum was finally launched on the 5th of May 2023, to include principles of inclusiveness, diversity, openness and transparency.

During the launch of the Wildlife Well-being Forum a member of WAPFSA, the EMS Foundation, raised the issue of perpetuated inequality when it became apparent that members of the exclusive Wildlife Forum have been invited to join the Wildlife Well-Being Forum. WAPFSA welcomes inclusivity, transparency, accountability and openness but we must insist that DFFE employs an equal and even-handed approach to stakeholder engagement.

The minutes of the Consultative Wildlife Forum are not publicly available even though government policy discussions and decisions relating to the sustainable use of South Africa’s biodiversity should be transparent. Members of WAPFSA have had to resort to the legal and time-consuming process of submitting a number of applications in terms of the Promotion of Access to Information Act 2 of 2000 (PAIA), to obtain such minutes. Response to various PAIA applications has returned with relevant parts of the Wildlife Forum minutes redacted – including member and organisational names – in order to try and omit information which is of public interest.

Our legislation states that the treatment and management of South African wildlife is a matter of public interest and all consultative meetings with the industry representatives should be open to all relevant stakeholders, Interested and Affected Parties and observers.

In addition, many of the organisations that work within the animal protection sector are also working within the wildlife conservation framework, indicating that conservation and protection are not two different and diverging sectors to be consulted separately and most importantly, under a different set of conditions.

The notion of public participation in all spheres of government is embedded in the Constitution of the Republic of South Africa. The Promotion of Administrative Justice Act, Act 3 of 2000 (PAJA) is also linked to public participation. Procedural fairness stipulates the necessity for a participatory process, PAJA necessitates a process of public participation through section 4 of the Act, which to its extent allows for more informed and defensible decisions with a greater potential of support by the public.

The National Policy Development Framework approved by Cabinet in 2020, highlighted that a number of laws were overturned by the courts because of technical deficiencies in their Constitutionality and the process of consultation. The policy framework recommended truly inclusive public participatory processes and made clear that “stakeholder consultation is non-negotiable and must strive for genuine stakeholder involvement rather than simple malicious compliance with the Constitution and other laws”.

In terms of Privacy, the treatment of personal information and personal interests in the public space, in the case Bernstein and Others v Bester NO and Others 1996 (4) BCLR 449 (CC); 1996 (2) SA 751 (CC), the Constitutional Court clearly established that: […] the fact that no right is to be considered absolute, implies that from the outset of interpretation, each right is always already limited by every other right accruing to another citizen. In the context of privacy, this would mean that it is only the inner sanctum of a person, such as his/her family life, sexual preference and home environment, which is shielded from erosion by conflicting rights of the community. This implies that community rights and the rights of fellow members place a corresponding obligation on a citizen, thereby shaping the abstract notion of individualism towards identifying a concrete member of civil society. Privacy is acknowledged in the truly personal realm, but as a person moves into communal relations and activities such as business and social interaction, the scope of personal space shrinks accordingly.’

The continued existence of the exclusive Wildlife Forum, which has historically operated in a bubble and behind closed doors, under a non-disclosure clause is unfair, unconstitutional, unnecessary and non-compliant with a number of laws, policies and guidelines.

As mentioned, during the public launch of the Wildlife Well-being Forum members of the Wildlife Forum have been given the opportunity to apply and join a more inclusive and transparent process. We respectfully, therefore, request the closure of the Consultative Wildlife Forum as established in 2005.

Alternatively, we ask that the Wildlife Forum be reconstituted to conform with the way that the Wellbeing Forum is constituted. To achieve this, industry representatives could observe Well-being Forum meetings but not participate and Well-being Forum representatives could observe Wildlife Forum meetings but not participate. This will promote transparency and efficiency while avoiding conflict during meetings.

WAPFSA also requests the unredacted disclosure of all minutes and records from the aforementioned Wildlife Forum for public scrutiny.

WAPFSA acknowledges and values the Honourable Minister’s continued efforts toward achieving fair processes and a more transparent and inclusive way to engage with stakeholders and civil society in relation to wildlife policy and we look forward to a positive and constructive working relationship with your department and other stakeholders.

©WAPFSA 2023. All Rights Reserved.





The Wildlife Animal Protection Forum of South Africa is an alliance of twenty-four South African organisations that share certain values, knowledge and objectives and who collectively contribute to a body of expertise from the scientific, conservation, legal, welfare, rights, social and climate justice and public advocacy sectors.

The undersigned Members of WAPFSA and their colleagues in wildlife conservation hereby extend their congratulations and offer their official gratitude to the Democratic Alliance for their forward-thinking decision to adopt a policy resolution against the practice of captive or canned lion hunting, the breeding of lions for the intent of canned lion hunting and the breeding of lions for the sale of their bones and other derivatives.

Five years ago, in 2018, the 5th Parliamentary Committee on Environmental Affairs adopted a Report compiled during a two-day Colloquium on Captive Lion Breeding for Hunting in South Africa: Harming or Promoting the Conservation Image of the Country.

The Colloquium achieved an exceptionally high turnout, drawing speakers and participants from the captive lion breeding industry, hunting associations, conservation and animal protection organisations and the government.

Two members of WAPFSA presented the results of an eighteen-month investigation into the captive lion industry published in a Report titled: The Extinction Business: South Africa’s Lion Bone Trade.

According to the Report of the Portfolio Committee, which was later adopted by Parliament, there was a predominant view that the captive lion breeding industry did not contribute to conservation and was doing damage to South Africa’s conservation and tourism reputation.

The captive breeding of lions for hunting and lion bone trade came under severe criticism from both local and international conservation organisations for harming South Africa’s well-established and highly respected conservation image.

The then Portfolio Chairperson, Honourable Mr Philemon Mapulane, remarked that although South Africa is in favour of sustainable use of biodiversity resources, South Africa finds itself increasingly isolated at important international conservation platforms as a result of the captive lion industry. It seems as if South Africa’s conservation reputation is being compromised by this practice which does not seem to benefit the broader conservation, but a small number of breeders without proper scientific or conservation basis. Parliament, he warned must become particularly concerned when reputable conservation agencies such as the International Union for Conservation of Nature turn their backs and deplore these practices.

In May 2021 a Press Release, issued by the Parliamentary Communication Services on behalf of the Portfolio Committee on Environment, Forestry and Fisheries, Mr Fikile Xasa, stated that the Portfolio Committee welcomes the announcement made by the Minister of Environment, Forestry and Fisheries, that South Africa plans to ban the breeding of lions in captivity for trophy hunting or for tourists to pet.

The Chairperson of the committee, Mr Fikile Xasa said: “It was indeed satisfying to have attended the launch of the Report of the High-Level Panel that agreed with our parliamentary resolution to consider banning this destructive practice for the greater public good, our conservation brand and the dependant tourism industry. As public representatives, we feel our people have been heard.”

We are relying upon the Democratic Alliance to continue to be a strong voice in order to strengthen the enforcement of the closure of this abhorrent industry in order to save and preserve South Africa’s conservation reputation and to preserve lion populations in the wild for future generations.


Mr Henry Smith, MP Crawley Constituency House of Commons, London
Will Travers OBE, Co-Founder and Executive President Born Free Foundation
Richard Peirce, Author “Cuddle Me, Kill Me”, Investigator “Lions, Bones & Bullets”
Eduardo Goncalves, Founder of the Campaign to Ban Trophy Hunting
John Read, International Director Campaign to Ban Trophy Hunting
Daniela Freyer, Co-Founder Pro Wildlife e.V.
Dr Barbara Maas, Founder and Chief Executive, People for Nature and Peace

Sairusha Govindsamy, Climate Program, African Climate Alliance, South Africa
Dave Du Toit, Founder, Vervet Monkey Foundation, South Africa
Fiona Miles, Director, Four Paws (SA)
Jabu Myeni, Env, Education Programme, Gifted for Good, South Africa
Les Mitchell, Director, Institute for Critical Animal Studies (Africa)
Lex Abnett, Director, Southern African Fight for Rhinos, South Africa
Linda Tucker, CEO Founder, Global White Lion Protection Trust, South Africa
Lizaene Cornwall and Catherine Nyquist, Co-Founders, Panthera Africa Big Cat Sanctuary, South Africa Megan Carr, Founder, Rhinos in Africa, South Africa
Michele Pickover, Executive Director, EMS Foundation, South Africa
Renee Bish and Peter Oxford, Co-Founders, Betty’s Bay Baboon Action Group, South Africa
Sera Farista, Climate Justice Campaigner, Youth Climate Group, South Africa
Smaragda Louw, Director, Ban Animal Trading, South Africa
Stefania Falcon, Co-Founder, Future 4 Wildlife, Africa
Stephen Fritz, Indigenous Leader, South Peninsula Khoi Council, South Africa
Stephen Munro, Director, Centre for Animal Rehabilitation and Education, South Africa
Steve Smit, Co-Founder, Monkey Helpline, South Africa
Toni Brockhoven, Chairperson, Beauty Without Cruelty (South Africa)
Vivien Law, Regenerative Farming Program, Parliament for the People, South Africa
Wynter Worsthorne, Founder of Animal Talk Africa, South Africa

Image Credit: EMS Foundation

©WAPFSA 2023. All Rights Reserved.



The Department of Environmental Affairs acknowledged receipt of the Appeal submitted by Members of WAPFSA on the 10th of May 2023.

WAPFSA registered as an Interested and Affected Party and has previously submitted preliminary comments to the Draft Scoping Report and the Members of WAPFSA have also submitted comments on the Environment and Social Impart Assessment.

©WAPFSA 2023. All Rights Reserved.


Members of the Wildlife Animal Protection Forum South Africa delivered a submission with their comments on the Draft Cape Peninsula Baboon Strategic Management Plan on Friday 31st March 2023.


The Plan should be titled: CAPE PENINUSULA HUMAN-BABOON CO-EXISTENCE STRATEGIC MANAGEMENT PLAN (HBCEMP) this will speak to a more useful framework to help support more sustainable people-nature interactions in the context of the conservation of African baboons to achieve human-baboon coexistence, by balancing the integrity of nature with human wellbeing. A new ethos is necessary to ensure changes not only to what is done but how things are done. The MP should be based on Ubuntu and within the context of changing people’s attitudes to Nature and wild species so that they understand that their conservation is essential to the long-term flourishing of humanity and aspire to co-exist harmoniously within Nature instead of simply regarding wild species as merely economic “resources” or “damage-causing”.

WAPFSA believes that this merits a separate goal (Ubuntu and harmonious co-existence within Nature are promoted) which focuses on how conservation will be undertaken in future, with an emphasis on applying ethics such as Ubuntu to change how people view, and relate to Nature, and to contribute to ways for people to co-exist with wild species so that life in all its diversity can be sustained and that human wellbeing is increased as a consequence of protecting and restoring natural ecosystems instead of at their expense.

The Plan cannot be developed in a vacuum. It therefore must include a preface which provides the overarching context and background in relation to South Africa’s primate populations including the lack of credible data, the urgent need for a population census, regulation and oversight insufficiencies and the outdated legislative framework (both provincially and nationally) – for example, sections of the Western Cape Biodiversity Act have not come into effect, particularly the Ordinance has not been repealed and this relates specifically to the status and killing of baboons. Please take note of the contents and findings of this 2023 research report on South Africa’s nonhuman primates: 

Transformational changes (game-changing shifts) are urgently needed if we are to secure humanity’s future. To do this we need to address the interlinked emergencies of human-induced climate change and the loss of wild species. What is needed is a progressive vision and policy for conservation based on the ethic of Ubuntu and the recognition that humanity can only flourish in the long term by conserving the natural systems that support all life and finding ways to coexist in harmony with Nature.

Conservation policies and decisions must be guided primarily by ecological and welfare considerations, i.e. decisions about wild species and biodiversity must be based on ecological considerations (e.g. what is best for the ecosystem) and welfare considerations (e.g. treating wild animals with respect and without cruelty both for their own sakes and to foster consideration for other species in accordance with the ethic of Ubuntu.

WAPFSA notes that some organisations are of the opinion that the entire BSMP process is flawed and illegal. This needs to be taken seriously and investigated by the JMC to determine if all the necessary steps in this process were correctly followed.

WAPFSA wants to place on record that there are transparency and accountability concerns as stakeholders were not provided with the Terms of Reference of the CPBMJTT or the Memorandum of Agreement between the three parties. These are essential documents to verify policy, budget, or resources, amongst other things, from and between the three spheres of government involved. In addition, stakeholders were never informed of the criteria for the selection of the members of the CPBMJTT and had no opportunity to comment on such criteria.

WAPFSA requests that any changes to the existing Baboon Management programme be consultative and inclusive of all stakeholders.

WAPFSA is concerned that the City of Cape Town (“COCT”) Urban Baboon Programme is to be terminated in June 2023 with apparently no plan in place to ensure the safety and well-being of the Peninsula baboons. If the programme is resumed, WAPFSA is of the view that the protocols for the monitoring of baboons needs to be re-examined and re-imagined, through wide stakeholder consultation.

WAPFSA urgently requests a moratorium on the killing of baboons while the Management Plan is being amended, updated, consulted on, and implemented.

Image Credit: Jenny Parsons Pringle Bay, South Africa

©WAPFSA 2023. All Rights Reserved.


Jagd und Hund Hunting Fair in Dortmund, Germany (Image Credit 2022)


24TH – 29TH JANUARY 2023

Advertised is the largest most prestigious shopping paradise for hunters, the 41st Jagd Und Hund is a trade show held annually in Dortmund in Germany, this year the show will be take place from the 24th to the 29th of January 2023.

Tens of thousands of animals are hunted and killed by hunters who pay handsomely for this pleasure. Many European and British citizens are losing the appetite to continue to support or participate in the colonial sport of trophy hunting.

This is an open letter written to the Mayor of Dortmund which has been signed by members of WAPFSA, members of the Pro Elephant Network and endorsed by a number of world renown wildlife conservationists, wildlife veterinarians, international dignitaries, politicians and environmental lawyers.

Please find the OPEN LETTER:

Image Credit:

©Wildlife Animal Protection Forum South Africa 2023. All Rights Reserved.


Members of the Wildlife Animal Protection Forum Formally Distance Themselves from WILDCHOICES

A formal communication was delivered to the owners of WildChoices and the South African Tourism Services Association on Wednesday 7th of December 2022.


The Wildlife Animal Protection Forum South Africa (WAPFSA), is a network of thirty-one diverse South African NGOs that share certain values, knowledge and objectives, and that collectively comprise a body of expertise in various fields in South Africa, from scientific, conservation, and welfare, rights, tourism, social justice, indigenous rights, public advocacy sectors and the law.

The South African Tourism Services Association (SATSA) is a member-driven, non-profit association representing the private sector. In 2018 SATSA established a Board Committee on Captive Wildlife Interactions and commissioned BDO South Africa, an independent consulting firm, to:

  1. Define the types of entities that fall within the ambit of captive wildlife interactions including standardising definitions and terminology;
  2. Develop an ethical framework to evaluate operations that involve captive wildlife interactions to underpin the debate and establish the principles upon which the ethicalness of animal interaction operations may objectively be evaluated; and,
  3. Develop a set of guidelines for the self-regulation of captive wildlife interaction tourism experiences.

In November 2019 SATSA published their Captive Wildlife Attractions and Activities Guidelines and Decision Tool which is endorsed by a number of organisations.

Apparently, in 2021, two members of the 2018 SATSA Board Committee, Brett Mitchell and Gavin Reynolds founded WildChoices which is owned by Wildly Adventures (Pty) Ltd (reg No: 2020/635217/07), to identify and assess all the captive wildlife interaction facilities in South Africa using the SATSA Guidelines and Decision Tool.

According to the information on the website: ‘WildChoices assists local and international tour operators, agents, and individual travellers to make informed, ethical choices about captive wildlife tourism facilities in South Africa’. WildChoices employs the SATSA Decision Tree to make its assessments.
After receiving complaints about various listings on the WildChoices website, WAPFSA conducted internal research and discovered numerous potentially problematic listings, for example, WildChoices has listed zoos, petting zoos and facilities that have traded wild animals as places to “support with caution”.

WAPFSA organisations do not support the captive wildlife industry, especially where animals are utilised for entertainment and/or breeding for trade.
It is an additional concern that animal welfare issues and trophy hunting are not considered in the SATSA Decision Tree.

As testimony to the fact that this Tool is faulty and inaccurately applied, a Member of WAPFSA has been wrongly listed on the WildChoices’ website. To be more specific, the Global White Lion Protection Trust (“GWLPT”) has been listed as a facility to avoid”. GWLPT is a non-profit, non-commercial organisation, and not a tourist facility – and therefore does not qualify for listing in the first place. Some of our members have objected to this inaccuracy to WildChoices and have asked specific questions of relevance, which have not been answered by WildChoices.

Until such time as these errors are corrected and the Tool is vetted by WAPFSA as a valid measure of unethical establishments, we as a forum cannot support or be associated with this initiative. We therefore formally distance ourselves from the WildChoices listing.


Image Credit: EMS Foundation

©WAPFSA 2022. All Rights Reserved.